Privacy Policy

The controller within the meaning of Article 4(7) GDPR is:

konax media Günther Fick GbR
Weberstraße 30
23966 Wismar
Germany
Email: info@konax-media.de
Phone: +49 176 86262895

Contact for privacy questions: Konstantin Günther - info@konax-media.de

This Privacy Policy applies to the Dumplie iOS app. When you visit konax-media.de, the general website privacy policy also applies.

You can use Dumplie without registering or creating an account. We do not operate our own user or game-state server for the game. Your game state and settings generally remain on your device. Network connections are made to Google for consent management and advertising and to Apple for product information, purchases, and verification of Premium access.

Dumplie stores the data needed to provide the features you select on your device:

• Your high score, discovered dumplings, and an active round
• Game-state data such as points, characters, positions, combinations, and whether a revive has already been used in the round
• Language and settings for music, volume, sound, and haptic feedback
• Your selected Dumpling Pack
• Your use and daily balance of free Premium revives
• The time of the last full-screen ad so that ad intervals can be observed

This data is not transmitted to us. It is processed to provide the game and the settings you expressly request. The legal basis is Article 6(1)(b) GDPR. Storage on the device is permitted under section 25(2)(2) TDDDG to the extent strictly necessary to provide the app features you request.

The data remains stored until it is overwritten by the app, removed by the operating system, or the app is deleted. You can completely remove this local data by deleting Dumplie. If your device includes app data in a device or iCloud backup, storage and deletion depend on your Apple settings. We cannot access these backups.

Dumplie uses Apple StoreKit to display the price of the one-time Premium purchase, process purchases through the App Store, restore existing purchases, and verify Premium access. The provider is Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. Other Apple entities may be responsible depending on your place of residence.

Apple handles payment and your Apple Account. Dumplie receives from StoreKit the product and transaction information and verified entitlement status required to unlock Premium. We do not operate our own purchase server and do not receive full payment details such as credit-card or bank-account information through the app. The legal basis for unlocking and managing Premium is Article 6(1)(b) GDPR. Apple processes App Store data under its own responsibility and provides details in App Store & Privacy.

Dumplie does not offer user accounts and does not use first-party analytics, profiling, social-media, location, contacts, photos, microphone, or health services. We do not operate our own crash reporting. This does not affect the Google processing related to ads or the Apple processing related to the App Store described above.

If you contact us by email, we process your email address, the content of your message, and any other information you voluntarily provide in order to handle your request. The legal basis is Article 6(1)(b) GDPR where the request concerns a contract or purchase, and otherwise Article 6(1)(f) GDPR. Our legitimate interest is responding to inquiries and supporting the app.

Your message is sent through the email provider you choose. Our mailbox is technically operated by STRATO AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany, as a processor. The data is deleted once the matter has been resolved, unless statutory retention or evidence obligations require longer storage. See the STRATO Privacy Policy for more information.

Personal data is made available only to parties that need it for the purposes described. These may include Google and selected advertising partners, Apple, STRATO and the email provider you use, and authorities or courts where disclosure is legally required. Any other disclosure takes place only with consent or on another statutory basis.

We disclose personal data only to parties that are contractually or legally required to provide the same or an equivalent level of protection as described in this Privacy Policy and required by the App Store rules applicable to Dumplie.

Google, advertising partners, and Apple may process data outside the European Economic Area, particularly in the United States. Transfers take place in accordance with Articles 44 et seq. GDPR, in particular on the basis of an adequacy decision such as the EU-US Data Privacy Framework for certified recipients or the European Commission's Standard Contractual Clauses with any necessary supplementary safeguards.

Information about the safeguards used and the availability of the Standard Contractual Clauses is available from Google, Apple, and the European Commission. You can also request a copy of the safeguards relevant to a specific processing activity at info@konax-media.de, insofar as this does not adversely affect the rights of third parties.

The periods stated in the relevant sections apply to local app data, UMP choices, and contact requests. Google, advertising partners, and Apple retain data under their own deletion policies and legal obligations. Specific periods may vary according to data type, purpose, region, and account setting. Aggregated or effectively anonymized data may be retained longer where it can no longer be linked to an individual.

Because Dumplie has no user accounts and we operate no user or game-state server, we cannot remotely access or erase local app data. You can remove it by deleting the app. You can request deletion of personal data from a support request at info@konax-media.de. Where Google or Apple acts as an independent controller, you may also submit access or deletion requests directly to that provider.

You are not legally or contractually required to provide personal data to us or to consent to advertising or tracking. Dumplie remains playable without tracking permission and without consent to personalized advertising. Depending on your region, consent status, and available demand, non-personalized, limited, or no ads may then appear. A voluntary ad-based revive is available only when Google supplies a suitable ad.

The Premium purchase is voluntary. Without the processing required by Apple, the purchase cannot be completed, restored, or verified on a device. Contacting us by email is also voluntary; without the information needed to process your request, we may be unable to answer it.

Subject to the statutory requirements, you have the right of access (Article 15 GDPR), rectification (Article 16 GDPR), erasure (Article 17 GDPR), restriction of processing (Article 18 GDPR), data portability (Article 20 GDPR), and objection (Article 21 GDPR). You may withdraw consent at any time with future effect (Article 7(3) GDPR). This does not affect the lawfulness of processing carried out before withdrawal.

Where processing is based on Article 6(1)(f) GDPR, you may object at any time on grounds relating to your particular situation. You may object to direct marketing without giving reasons.

Send requests to info@konax-media.de. Where Google, an advertising partner, or Apple processes data as an independent controller, you may also exercise your rights directly with that provider.

Under Article 77 GDPR, you may lodge a complaint with a data protection supervisory authority. The authority generally responsible for us is:

The State Commissioner for Data Protection and Freedom of Information Mecklenburg-Western Pomerania
Werderstraße 74a
19055 Schwerin
Germany
Phone: +49 385 59494 0
Email: info@datenschutz-mv.de
www.datenschutz-mv.de

We do not make decisions based solely on automated processing within the meaning of Article 22 GDPR that produce legal effects concerning you or similarly significantly affect you. If you provide the required consents, Google and the advertising partners identified in the UMP form may create usage and interest profiles to select personalized ads and measure their performance. Dumplie disables ad personalization without those permissions.

Dumplie is not directed to children and is intended only for people at or above the elevated age rating displayed in the relevant App Store. The app does not collect a date of birth or perform its own age verification. Minors below that rating should not use the app; parents and guardians can use the device's parental and purchase controls.

We use appropriate technical and organizational measures to protect personal data against loss, unauthorized access, and alteration. This Privacy Policy will be updated if app features, providers, or legal requirements change. The version published at this address is the current version.

Effective date: 09.09.2026